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www.ctcgroupe.com Fall 2015 REACh Regulation: understand the basic principles. p. 6

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Page 1: CTC International Fall 2015

www.ctcgroupe.com

Fall 2015

REACh Regulation: understand the basic principles. p. 6

Page 2: CTC International Fall 2015

2 [CTCinternational] Fall 2015

For over 100 years, CTC has been providing clients with leather goods, footwear and clothing expertise. Be it for an SME with refi ned expertise or a multinational manufacturing company (industrial, brand or distributor), the globalisation of business relations and rapidly increasing pace of international trade mean companies must have complete control over their sourcing and logistics fl ow.

Assuming even further corporate social, societal and environmental responsibility within the context of these business relations is more important than ever.

Another key point in our clients' development is information access and control, especially in terms of regulations. To achieve this, CTC relies on its experts. This network is constantly monitoring the international situation and maintains a dual presence in the countries where the product is consumed and where it is produced. Such surveillance not only gives in-depth insight into market expectations and restraints, but also sheds light on production diffi culties.

To help you meet these market expectations, this edition contains:- CTC's latest developments to help you improve your performance;- information on regulatory and technological developments (REACh

and certifi cation of personal protective equipment);- access routes to this information (CTC seminar and training).

We are always here to help. Please don't hesitate to share your comments or suggestions regarding this publication.

Enjoy reading, and thank you for your support.

EditoFFgg

eoicc

Arii

A

Jean-Luc ChaverotDevelopment and International Manager of CTC

3 News

CTC SOLUTIONS 4 REACh Regulation: understand

the basic principles

INTERNATIONAL SERVICES6 CTC’s PPE worldwide services

CTC EVENTS7 Next CTC Seminars

Moda Shanghai - Shanghai (China), 31 August-2 September 2015Booth E2-B05a

Première Vision Leather Villepinte (France), 15-19 September 2015 Booth Hall 3 D51-E52

A+A - Düsseldorf (Germany), 27-30 October 2015

Traffic - Paris (France),4-5 November 2015

OSH India Mumbai - Mumbai (India), 26-27 November 2015

ExpoRivaSchuh - Riva del Garda (Italy), 10-13 January 2016

Come & see us at international fairs

CTC INDIANoidaChennai

Ho Chi Minh VilleHaiphong

CTC VIETNAM

CTC TUNISIAMégrine

CTC SPAINElda

CTC BANGLADESHDhaka

CTC LyonCTC ParisCTC Cholet

FRANCE

CTC CAMBODIAPhnom Penh

CTC ShanghaiCTC Asia (Hong Kong)CTC DongguanCTC WenzhouCTC XiamenCTC Houjie

CHINA

CTC INDONESIASurabaya

CTC HEAD OFFICE

CTC AGENCIES

CTC SERVICE CENTERS

CTC PARTNERSHIPS

Page 3: CTC International Fall 2015

Fall 2015 [CTCinternational] 3

NEWS

NEWS Accreditation

Sustainability: CTC’s expe� s accredited by SAC

The SAC, Sustainable Apparel Coalition has accredited CTC’s experts in Europe, China and India, as offi cial “SAC Verifi ers”. They can now help companies to determine the sustainability of their suppliers and factories. SAC is the largest trade organization of brands, retailers,

manufacturers, government, non-governmental organizations and academic experts.This team is driven by André Leroy, CSR Offi cer of CTC Groupe and Sales Director for Greater China. He said: “SAC standard is a great move for the apparel and footwear industry: it gives the opportunity to go to a unique standard. With this standard, the industry will give in the future the consumers the tools to make their fi nal choice. This fi rst move will meet companies growing needs to assess the sustainability of their supply chains and CTC’s SAC Verifi ers are in well positioned to bring them their expertise to assess supply chain sustainability”.

[email protected]@ctcgroupe.com

Appointment

André Leroy, a new Sales Director & CSR Offi cer

André LEROY has been appointed Sales Director for CTC Greater China and Corporate Social Responsibility for CTC Groupe. Previously Global Compliance Program Manager for Avery Dennison and former Manager of international laboratories, André has a strong experience and knowledge in the Apparel Industry, Sustainability

and Testing Services. For Yves MORIN, CEO of CTC, “André’s arrival represents a key element in CTC’s development and will allow to strengthen its specialization in Fashion Industry and Sustainable Development”. André LEROY is based in Hong Kong.

[email protected]

Market

UE and Vietnam: a Free Trade-Agreement!After two and a half years of negotiations, the European Union and the Socialist Republic of Viet Nam have reached an agreement in principle for a free trade agreement (FTA). This agreement will remove nearly all tariff s on goods traded between the two economies and “will boost trade with one of Asia’s most dynamic economies” EU Trade Commissioner Cecilia Malmström said.

[email protected]

Development

CTC India strengthening its position in PPE CTC India reinforced its position in the Personal Protective Equipment industry with the development of the testing services for protective gloves and safety footwear. As CTC extended the certifi cations for Russia, South Africa and Malaysia markets, CTC India is ready to carry out physical testing to obtain offi cial certifi cation for each country.Note that a new inspection area is available at Calcutta.

[email protected]

Congress

UITIC’s Call for Papers is launched!The Council for Leather Exports (CLE) India will organize the 19th Congress of the UITIC (International Union of Shoe Industry Technicians) during February 3rd to 5th 2016 in Chennai, India. Brands, footwear manufacturers and experts will join together to discuss the Future of the Footwear Factory as well as innovations in the footwear Industry. Two categories of presentation will be proposed: 20 min spoken presentation and visual presentation with a poster. Authors have until September 30, 2015 to submit their paper with the Abstract Submission Yves MORIN, CEO of CTC, is the President of UITIC since 2010.

Form available at http://uitic-congress.cleindia.org

Obituary

Roland Steyns has passed away It is with great sadness that we announce the passing of Roland STEYNS. Roland was a quiet, effi cient, courteous and pleasant man, always available for clients and colleagues.As a skilled professional, Roland has developed a strong understanding of

footwear global supply markets, within both Fashion and Sport Industries.He strongly contributed to the set-up of CTC Dongguan in 2007 (China) and Roland left CTC with fond memories of him. We all regret him and our condolences go out to his family and friends.

ASIA

Shanghai - ChinaTel.: +86 21 68 55 50 [email protected]

Dongguan - ChinaTel.: +86 769 23 03 77 [email protected]

Hong Kong - ChinaTel.: +852 24 29 70 [email protected]

Wenzhou - ChinaTel.: +86 577 28 80 10 [email protected]

Xiamen - ChinaTel.: +86 59 25 09 20 [email protected]

Houjie - ChinaTel.: +86 769 81 52 06 [email protected]

Noida - IndiaTel.: +91 12 04 87 11 [email protected]

Chennai - IndiaTel.: +91 44 28 30 50 [email protected]

Dhaka - Bangladesh Tel.: +880 2 841 [email protected]

Ho Chi Minh City - Vietnam Tel.: +84 8 38 27 44 [email protected]

Surabaya - Indonesia Tel.: +62 31 28 99 72 [email protected]

Phnom Penh - CambodiaTel.: +855 23 962 [email protected]

EUROPE & AFRICA

Lyon, Paris, Cholet - FranceTel.: +33 (0)4 72 76 10 [email protected]

Spain - [email protected]

www.ctcgroupe.com

Page 4: CTC International Fall 2015

4 [CTCinternational] Fall 2015

CTCSOLUTIONSCCR

EA

Ch

Reg

ulat

ion Under the European REACh regulation, a pair of

shoes, a leather item or a pair of gloves are articles. Materials required for the manufacturing of these

fi nished articles are also articles (leather, textiles, polymers or metal fi ttings).Any article placed on the European market must comply with the general product safety requirement laid down in Directive 2001/95/EC. The REACh regulation supplements this general requirement by regulating the use of chemical substances.

SUBSTANCES SUBJECT TO RESTRICTIONSome chemical substances associated with a material (e.g. a textile), a type of article (e.g. a childcare article) or with the guidelines for use (e.g. articles that come into contact with the skin) must not exceed the regulatory threshold limits. For example, carcinogenic aromatic amines must have a concentration of less than 30 mg/kgin any leather and textile parts that may come into direct and prolonged contact with the skin. For hexavalent chromium, the limit is set at 3 mg/kg for leather articles that may come into contact with the skin, either directly or indirectly, and regardless of the duration of this contact.These thresholds are published in Annex XVII of the REACh regulation which specifi es the restrictions imposed on the manufacture, placing on the market and use of certain dangerous substances. Annex XVII is not specifi c to the leather, footwear, leather goods and glove industries and includes requirements targeting other sectors or types of articles. Overall, there are about twenty restrictions which must be taken into account for apparel and footwear.If the concentration of the substance in the article to which the restriction applies exceeds the threshold limit in Annex XVII, the article can not be placed on the European market, whether it was manufactured in or outside the European Union. Other European legislation imposes restrictions on the presence of chemical substances in articles. For example,

Regulation no. 850/2004 on persistent organic pollutants (the so-called "POP Regulation"). Some Member States also have specifi c national restrictions (e.g. the restriction of lead in articles in Denmark).

SUBSTANCES OF VERY HIGH CONCERNThe REACh regulation imposes specifi c requirements on substances identifi ed as being of very high concern (such substances are referred to as SVHC which stands for "Substances of Very High Concern"). These are substances that meet at least one of the following criteria:- carcinogenic, mutagenic or toxic for reproduction

category 1A or 1B (CMR);- persistent, bio-accumulative and toxic;- very persistent and very bio-accumulative;- substances for which there is scientifi c evidence

of probable serious eff ects to human health or the environment, for example, endocrine disruptors.

The objective of the European Union is to ban these SVHCs by listing them in Annex XIV of the REACh regulation. REACh has two very distinct requirements relating to these SVHCs which are detailed in what follows:- a duty to communicate;- a ban on use in Europe.

Duty to communicate

On the basis of a proposal from a Member State, a substance can be offi cially identifi ed as a SVHC. It is then added to the candidate list of substances of very high concern (the so-called "Candidate List") for eventual inclusion in Annex XIV of the REACh Regulation. To date, 163 substances have been identifi ed as being of very high concern. This candidate list is updated every six months, with the aim being to have a defi nitive list by 2020.These SVHC candidates are not banned. However, if the SVHC is present in the article at a concentration of more than 0.1% (=1,000 mg/kg), the supplier is obliged to inform his customers of the presence of this substance.

CTC Solutions

REACh Regulation: understand the basic principlesThe REACh regulation came into force in June 2007. Year after year, "REACh" constraints have been taken into account in the RSLs (Restricted Substances Lists) of major brands for footwear, leather goods or clothing. However, interpretations of the regulation are sometimes surprising. For this reason, the CTC Department of Sustainable Development and Corporate Social Responsibility wishes to clarify a few points regarding the main principles of this founding legislation.

Page 5: CTC International Fall 2015

Fall 2015 [CTCinternational] 5

This duty to commucate applies to all the actors in the supply chain. However, the rule is diff erent when selling to an end consumer: communication is obligatory only if requested by the consumer and the supplier must respond within 45 days.

Ban on use in Europe

The European Chemicals Agency (ECHA) periodically reviews the SVHC substances on the candidate list to determine those that should be banned as a priority via their inclusion Annex XIV of the REACh Regulation. To date, of the 163 substances identifi ed as SVHCs, 31 are included in Annex XIV, entitled "list of substances subject to authorisation".The principle of this annex is: chemical substances listed in Annex XIV are not allowed to be manufactured, imported or used on European territory unless an authorisation (temporary exemption) has been granted. The date of the ban does not correspond to the date the substance was added to Annex XIV; instead, it is determined for each substance in order to give the industries aff ected time to organise themselves. As a result of the ban on the use of substances in Annex XIV in Europe, it follows that articles produced on European territory would not contain these substances. However, articles manufactured outside of the European Union and placed on the European market may contain these

same substances; they will therefore be subject to the duty to communicate described above, insofar as these substances are SVHCs. To overcome this, the REACh regulation provides for the possibility of including a restriction in Annex XVII on substances listed in Annex XIV if the risk posed by the imported articles containing one of these substances is not properly controlled.

CONCLUSIONThe basic principles of the REACh regulation have been presented in a simplifi ed way by sorting the chemical substances into three types of requirements for those placing articles on the market: restriction, communication, ban. In practice, the same substance can be restricted under Annex XVII, appear on the list of SVHCs and be included in Annex XIV. This is the case, for example, with phthalate DEHP, making it diffi cult for manufacturers to understand. The CTC Department of Sustainable Development and Corporate Social Responsibility carries out a watch specifi cally for manufacturers in the leather, footwear, leather goods and glove industries to help them make sense of the requirements and overcome their practical consequences in business.

CTC, sustainable development for the leather and textile industries.

Authors

Thierry Poncet - Head of Sustainable Development [email protected]

Céline Astruc - Sustainable Development Consultant [email protected]

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REACh, three types of requirements

SUBSTANCES SUBJECT TO RESTRICTION

→ Annex XVII of REACh

→ Can not be placed on the market if they exceed the regulatory threshold

SUBSTANCES SUBJECT TO COMMUNICATION

→ List of SVHC candidate for inclusion in Annex XIV

→ Communication if SVHCs are present in the article at a concentration of more than 0.1 %

SUBSTANCES SUBJECT TO AUTHORISATION

→ Annex XIV of REACh

→ Ban on use in European processes (unless an exemption is granted)

Page 6: CTC International Fall 2015

6 [CTCinternational] Fall 2015

CTCSOLUTIONSCC

International Services

CTC’s PPE worldwide services CTC’s PPE Worldwide services in footwear and glove certi ication have now been extended to Russia (former GOST standards), South Africa and Malaysia. Companies targeting these countries are now able to carry out physical testing at CTC France, India or China prior to obtaining of icial certi ication for each country.

CTC’S OFFER FOR MOTORCYCLE RIDERSCTC provides physical and chemical testing for protective clothing including jackets, gloves, boots and trousers intended for motorcycle riders. These tests are provided in accordance with various standards: for protective gloves, tests respond to EN 13594. For footwear, tests are performed according to EN 13634. Eventually, EN 13595-1 is the standard that applies to protective clothing.

CHANGES TO PROTECTIVE GLOVE STANDARDSEvolution of standard EN 13594 for motorcyclists’ protective glovesIn the new standard prEN 13594 project, some compulsory requirements don’t change: pH value (leather and fabrics), Chromium VI content (leather), inclusion of hard elements, cuff length, cutting resistance (≥1,2).The changes to standard EN 13594 that applies to protective gloves for motorcycle riders aff ect two aspects: test methods are improved and the level of requirement become lower.The main changes concerning the compulsory requirements are:- Suppression of the colour fastness to perspiration test- Ergonomic requirements (new questionnaire

of the prEN13594)- Size- Maintain (new cones): dynamometer, test tube for fi nished

products, muff inserted in glove.- Tear strength (on cuff materials): dynamometer, materials

sample, tests according to EN ISO 3377-1 for leather and EN ISO 4674-1 for the other materials, recording of the strength linked to tear strength resistance.

- Seams resistance (requirements seams range ≥ 4N/mm)- Resistance to impact abrasion (mean abrasion time ≥4,0s,

single abrasion time ≥3,0s) + (according to the method of the prEN13594): standard EN13595-2, specifi c equipment, materials sample. The sample is carried up on an articulated arm. This arm pivots and makes the sample touch an abrasive strip. We measure the time needed to obtain a hole.

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Get more information at ctcgroupe.com/training

Chris [email protected]

Eastern China Sales Manager+86 13611764880

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Page 7: CTC International Fall 2015

Fall 2015 [CTCinternational] 7

Regarding the additional requirements, changes concern additional protection, mitigation of the impact energy (average ≤7kN, single value ≤9kN) + (according to the method of the prEN13594).The evolution of standard EN 13594 also includes a new marking and new instructions.Regarding general requirements about innocuousness, protective gloves for motorcycle riders must comply with the PPE directives requirements and the European regulation (REACh). Personal Protective Equipment must not be dangerous for users. Moreover, requirements depend on materials (leather or fabrics) and their colour. These requirements concern azoic dyes (all materials), PFOS/PFOA (any non-elastomeric material treated for water, Organotins (on a principal material), cadmium, nickel (metallic elements in contact with the skin).

Evolution of standard EN 388 for protective glovesRegarding the standard for protective gloves against mechanical risks, the signifi cant changes are:- The application to cuff materials- The improvement of the abrasion resistance test- The improvement of the cutting resistance test- Test and optional requirements for protection against shocks

The standard EN 374-1 related to protective gloves against chemicals and micro-organisms also evolves:- 3 types of gloves A-B-C- New permeation resistance test - New list of substances- New marking (pictogram)- Test on cuff material- Inclusion of resistance to chemical degradation test

Among the other changes, the test method of the EN 374-2 is improved and the EN374-3 is replaced by prEN16523-1. A new permeation resistance test (cell clarifi cation, temperature, detection...) is established.

Seminars

Next CTC SeminarsCTC is pleased to invite you to the following

seminars. Our experts will present the latest updates with regard to safety, regulations and

certi ication in gloves and footwear. Free entrance.

SUSTAINABILITYwww.aclechina.com

How to demonstrate sustainability of your

factories while minimizing costsA sustainability standard adopted by Brands that represent 1/3 of the apparel and footwear market worldwide that minimize duplication of assessments

Date: Monday, 31 August 2015

Time: 13:30 - 14:30Venue: Room E2 - M20, Shanghai New International Expo

Centre (SNIEC)Speaker: André LEROY, Sales Director - Sustainability

Offi cer, CTC Greater ChinaLanguage: presented in both English and ChineseContact: Liya Ji - Marketing Executive - CTC China

[email protected] (+86) 136 1194 9193

PERSONAL PROTECTIVE EQUIPMENTSafety Footwear and Gloves latest regulation

and technical guidelineThese seminars will focus on standardization and testing for Safety Footwear and Gloves.

Safety Footwear Date: Wednesday, 26 August 2015

Location: Wenzhou

Safety GlovesDate: Thursday, 24 September 2015

Location: Gaomi

Safety Footwear Date: Thursday, 24 September 2015

Location: Gaomi

Safety Footwear Date: Friday, 25 September 2015

Location: Yinan

Safety Footwear Date: Friday, 20 November 2015

Location: Dongguan

Speaker: Kevin LEE - PPE Supervisor - CTC DongguanLanguage: presented in both English and ChineseContact: Liya Ji - Marketing Executive - CTC China

[email protected] (+86) 136 1194 9193

Page 8: CTC International Fall 2015